IN THE COUNTY COURT OF THE ELEVENTH JUDICIAL CIRCUITIN AND FOR MIAMI DADE COUNTY, FLORIDA

GENERAL JURISDICTION DIVISION

CASE NO. 11 20527 CA 21

LTA LOGISTICS, INC.A Florida corporation, andLESTER TRIMINO,ANNETTE TRIMINO,LESTER TRIMINO SR.,

Plaintiff's and Defendant's in the counterclaim,

V.

Enrique Varona,

Defendant and Plaintiff in the counterclaim,

THE ORIGINAFILED ON:

NOV 1 6 2011

CIRCUIT COURT DADt CO

DEFENDANT'S MOTION TO REQUEST PRODUCTION

COMES NOW, The Defendant and Plaintiff in the counterclaim, Enrique Varona, proceeding

pro-se, (from hereon, "Varona") a human person and not a corporate fiction or statutory

person, hereby requests that the Plaintiffs and Defendant's in the counterclaim, LTA

LOGISTICS, Inc., LESTER TRIMINO, ANNETTE TRIMINO, and LESTER TRIMINO SR. (From

hereon, "Trimino") produce pursuant to Rule 1.350 of the Florida Rules of Civil Procedure,

the following documents at the residence of Varona: 14823 S.W. 125 Court, Miami, Florida

33186, within (30) thirty days from the date of the mailing and/or emailing of this document

for the purposes of inspection, copying, and/or reproduction of the following:

Production Instructions

1. All documents pursuant hereto are to be produced as they are kept in the usual

course of business or shall be organized and labeled (without permanently marking

the item produced) so as to correspond with the categories of each numbered

request.

2. Each draft, final document, original, reproduction, and each signed and unsigned

document and every additional copy of such document were such copy contains any

commentary, note, notation or other change whatsoever that does not appear on the

original or on the copy of the one document produced shall be deemed and

considered to constitute a separate document.

3. Unless another time period is specified, this request for production is addressed to

documents created since June 2009 and ended on the date of compliance with the

Request for Production.

4. Pursuant to Rule 1.280(b)(4), of the Florida Rules of Civil Procedure, effective

January 1, 1997 if you object to providing any discovery or fail to fully or fail to

provide and production on the grounds of privilege or protection of trial preparation

material, you are required to:

a. Make the claim directly;

b. Describe the nature of the documents, communications, or things not produced

or disclosed in a manner that, without revealing information itself privileged or

protected, will enable the party propounding this Request for Production to

assess the applicability of the privilege or protection.

5. In any of the documents encompassed by the attached for production of documents

is/are deemed by you to be privileged, furnish all non privileged documents.

6. When appropriate, the singular form of a word should be interpreted in the plural as

may be necessary to bring within the scope hereof any documents which might

otherwise be construed to be outside the scope thereof.

Requested Documents

1. Any and all documents that in any way memorialize or refer to any statements of

any party to this action, his/hers/its agents, employees, or any independent

witness or witnesses, bearing on any knowledge or facts that are either relevant

or that could lead to admissible evidence in the above styled lawsuit.

2. Any and all documents upon which you now have in your possession or control,

and which you believe you will rely upon should this matter be tried.

3. All correspondence between Trimino and Landstar Logistics, Inc. upon which the

above styled action is based and any of Varona and Trimino.

4. Copy of any and all agreements between Trimino and his attorney that provide for

fees to be paid and copies of all cancelled checks paid to the attorney for fees.

5. Certified copy of the alleged Non disclosure & Non solicitation agreement

between Varona and Trimino dated November 5th of 2009. For signature forensic

examination purposes.

6. Copies of all load reports provided by Varona to Trimino on a weekly basis.

7. Copies of all checks paid to Varona by Trimino including all commissions.

8. Address of the following employees: Todd Osipiak, Cristina Davis, Sebastian

Nandino, Leticia (last name unknown), Vickie (last name unknown) for service of

court papers related to depositions and witness at trial.

9. Address of all former or current employees whether active or terminated of (LTA

LOGISTICS, INC.) Trimino who have been hired since March 2009 to the present

for service of court papers related to depositions and witness at trial.

10. Name and address of all the alleged customers, clients, accounts, future

customers, vendors, that Varona allegedly contacted or solicited or interfered

with that are the subject of Trimino's action for the alleged tortous interference

claim against Varona, for service of court papers related to depositions and

witness at trial.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the forgoing was mailed on

November 16, 2011 to Scott Egleston P.A., 12000 Biscayne Blvd Suite 220,

Miami, Florida 33181.

Respectfully submitted,

Enrique Varona1382lfs\W. 125 CourtMiami, Florida 33186

Enrioue aorm, pro-se

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